< Back to Thought Leadership

Deferral of Revenue Recognition and Leases

This article was originally published with updates to FASB updates on December 10, 2019 and was most recently updated on June 5th. It is being updated as new information becomes available.

On June 3, 2020, the FASB issued Accounting Standards Update (ASU) 2020-05, Revenue from Contracts with Customers (ASC 606) and Leases (ASC 842) Effective Dates for Certain Entities, as part of its efforts to support and assist stakeholders as they cope with the many challenges and hardships related to the COVID-19 pandemic. This ASU provides the deferral to the effective dates of the ASCs as follows:

ASC 606 – Revenue Recognition from Contracts with Customers

ASU 2020-05 defers the effective date of ASC 606 for certain entities that have not yet issued their financial statements (or made financial statements available for issuance) reflecting the adoption of FASB ASC 606. Those entities may elect to adopt ASC 606 for annual reporting periods beginning after December 15, 2019, and interim reporting periods within annual reporting periods beginning after December 15, 2020. Early application continues to be permitted.

The effective date for a public business entity, a not-for-profit (NFP) entity that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market (public NFPs), and an employee benefit plan that files or furnishes financial statements with or to the Securities Exchange Commission is not affected by the amendments in this ASU.

ASC 842 – Leases

The effective date of ASC 842, Leases, is deferred as follows:

  • For private companies and other (non-public) NFPs, to fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022.
  • For public NFPs that have not yet issued (or made available for issuance) financial statements to fiscal years beginning after December 15, 2019, including interim periods within those fiscal years.

The ASU clarifies that a public NFP is eligible for the deferral if it has posted only interim financial information in the Electronic Municipal Marketplace Access (EMMA) system. Conversely, a public NFP is ineligible for the deferral if it has posted interim or annual U.S. GAAP-compliant financial statements in EMMA because that would be an issuance of financial statements. While financial information is a broad term that can vary widely in content from an earnings release to a balance sheet and income statement, U.S. GAAP-compliant financial statements is a widely-understood term and includes a full set of disclosures. The FASB acknowledges that a public NFP entity that has posted financial information on EMMA still may have significant remaining costs to complete its adoption of FASB ASC 842 to produce a full set of financial statements with disclosures.

Early application continues to be permitted.

For more information, refer to ASU 2020-05 on the FASB website.


December 10, 2019: FASB Defers Effective Dates for New Standards

The FASB deferred certain effective dates for its new standards on credit losses, hedging, and leases, and all of the effective dates for its new standard on long-duration insurance contracts.

Credit Losses Standard

The credit losses standard is now effective for all entities except SEC filers that are not smaller reporting companies for fiscal years beginning after December 15, 2022, including interim periods within those fiscal years. The Board also decided to align the effective dates of ASU 2017-04 on goodwill impairment with the amended credit losses effective dates.

Hedging and Leases Standards

The hedging and leases standards are effective for entities that are not public business entities for fiscal years beginning after December 15, 2020, and interim periods in the following fiscal year. For the leases standard, this also applies to entities that are not NFP entities that have issued, or are conduit bond obligors for, certain securities and not EBPs that file or furnish financial statements with or to the SEC.

Insurance Standard

The insurance standard is effective for SEC filers that are not smaller reporting companies for fiscal years beginning after December 15, 2021, including interim periods within those fiscal years, and for all other entities for fiscal years beginning after December 15, 2023, and interim periods a year later.

CMS Attempting to Clarify Some of the Regulations Around Medicare Bad Debt

CMS Attempting to Clarify Regulations Around Medicare Bad Debt 

Have you recently received Medicare bad debt audit adjustments that you felt were unfair? If so, you are not alone. MACs (Medicare Administrative Contractors) have been tightening their auditing standards and practices surrounding Medicare bad debt listings for years. Regulations have been interpreted and enforced differently by MACs, thus causing inconsistent audit standards. Being held to auditing standards […]

Learn More
Single Audit Reporting Package Deadline Rescission and Other Updates from OMB

Single Audit Reporting Package Deadline Rescission and Other Updates from OMB

On June 18, 2020, the Office of Management and Budget (OMB) issued Memorandum M-20-26, Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations, which will impact organizations that have received federal funds under the COVID-19 Emergency Acts and organizations that […]

Learn More